https://www.taxtmi.com/caselaws?id=464002 Reimbursement of salary costs and other expenditure paid to a foreign group entity, where no profit element is embedded, is not income chargeable to tax in the recipient's hands and therefore does not attract tax deduction at source under section 195. On that footing, the consequential disallowance under section 40(a)(i) cannot be sustained. The Court treated the legal questions as already concluded by an earlier judgment in favour of the assessee and, applying that principle, held that Article 13 of the India-UK Treaty did not change the result. en-us Tue, 06 Jul 2021 00:00:00 +0530 Fri, 26 Sep 2025 17:57:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464002 Reimbursement of salary costs and other expenditure paid to a foreign group entity, where no profit element is embedded, is not income chargeable to tax in the recipient's hands and therefore does not attract tax deduction at source under section 195. On that footing, the consequential disallowance under section 40(a)(i) cannot be sustained. The Court treated the legal questions as already concluded by an earlier judgment in favour of the assessee and, applying that principle, held that Article 13 of the India-UK Treaty did not change the result. Case-Laws Income Tax Tue, 06 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464002